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& E. Cmners, [1988] BTC 5160 (Q.B.D.)-- summary under Subparagraph 8(1)(i)(i) Summary Under Tax Topics- Income Tax Act- Section 8- Subsection 8(1)- Paragraph 8(1)(i)- Subparagraph 8(1)(i)(i) leisure and amenity management was not a profession The members of a non-profit organization formed to provide a central organization for persons described as engaged in the "profession" of leisure and amenity management, were not practising a "profession". ...

Keir & Cawder, Ltd. v. C.I.R. (1958), 38 TC 23 (C.S. (1st Div.))-- summary under Paragraph 111(5)(a) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(5)- Paragraph 111(5)(a) The taxpayer, which sold materials for use in construction projects, made a foray into the field of construction contracting which was terminated on the death of a consulting engineer whose services it had retained. ...

Keir & Cawder, Ltd. v. C.I.R. (1958), 38 TC 23 (C.S. (1st Div.))-- summary under Compensation Payments Summary Under Tax Topics- Income Tax Act- Section 9- Compensation Payments The taxpayer, whose main activity was carrying on the trade of quarrymasters, sought to extend its business to civil engineering contracting by retaining a firm of consulting engineers to provide the services and reputation of one of their engineers. ...

Capital City Savings & Credit Union Ltd. v. 299474 Alberta Ltd., [1990] 3 WWR 763 (Alta. ...

Abercorris Slate & Slabe Co. (1887), 37 Ch. D. 260, [1886-90] All ER 509-- summary under Investment Contract Summary Under Tax Topics- Income Tax Act- Section 12- Subsection 12(11)- Investment Contract Chitty J. stated (at Ch.D. p. 264): In my opinion a debenture means a document which either creates a debt or acknowledges it, and any document which fulfills either of these conditions is a "debenture. ...

P & O (Dover) Ltd. v. Commissioners of Customs and Excise, [1992] V.A.T.T.R. 221-- summary under Subsection 169(1) Summary Under Tax Topics- Excise Tax Act- Section 169- Subsection 169(1) The appellant along with seven individual employees was charged with manslaughter in connection with the sinking of its vessel. ...

Weisz Rocchi & Scholes v. The Queen, [2001] 2 CTC 2520, 2001 DTC 3705 (TCC)-- summary under Onus Summary Under Tax Topics- General Concepts- Onus Bowman T.C.J. indicated that the onus put on a taxpayer to challenge an assessment of the Crown did not apply where the Minister imposed a penalty: "It is contrary to the most fundamental precepts of the law and of ordinary procedural fairness that a government should be entitled to impose a penalty and then sit back and say to its subject: 'Show why you should not be penalized'. ...

Maden & Ireland, Ltd. (1959), 38 TC 391 (HL)-- summary under Capital Asset v. ...

Young, Austen & Young Ltd., [1989] BTC 77 (C.A.)-- summary under Subsection 86(1) Summary Under Tax Topics- Income Tax Act- Section 86- Subsection 86(1) In finding that an issuance of shares by a company to its existing beneficial shareholder, followed by the application of the subscription proceeds to pay off intercompany indebtedness, was a "reorganization... of a company's share capital" on ordinary principles, Balcombe L.J. stated: "an increase of share capital can be a reorganization of that capital... provided that the new shares are acquired by existing shareholders because they are existing shareholders and in proportion to their existing beneficial holdings. ...

Weiss, Biheller & Brooks, Ltd. v. Farmer (1922), 8 TC 381 (CA)-- summary under Paragraph 2(3)(b) Summary Under Tax Topics- Income Tax Act- Section 2- Subsection 2(3)- Paragraph 2(3)(b) agent distributor The taxpayer, which was an English company carrying on business as an importer and merchant, and which was the exclusive distributor of gas mantles manufactured by a Dutch company, was found to have been properly assessed as agent for the Dutch company in respect of profits derived by the Dutch company in carrying on a trade within the United Kingdom as vendor of the gas mantles, notwithstanding that there was no privity of contract between the English customers and the Dutch company, and that property in the mantles may have passed to the taxpayer. ...